ANSWER ED/2010/5
September 2010
CECA´s answer to IASB Exposure Draft on
Presentation of items of other comprehensive income
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CECA, the Spanish Confederation of Savings Banks (Cajas de Ahorros) was created in 1928 with the aim to join its members' forces and represent
Spanish Savings Banks Sector. CECA is formed of the 45 Spanish Savings Banks, which are one of the most important players in Spanish financial
system: their total assets reached €1.1billions, 24.050 branches in Spain and 124.139 employees in 2007.
Spanish Cajas are credit institutions that act and are organized as private enterprises. The have the legal status of private institutions. Spanish Cajas
are independent institutions which compete directly and individually with each other and with other financial institutions and they are free to decide
on their territorial expansion.
As credit institutions with foundational origins, Cajas pursue the following main objectives: (1) universal provision of financial services; (2) economic
efficiency; (3) promotion and competition and avoidance of monopolistic practices; (4) contribution to welfare and redistribution; and (5) promotion of
regional and community development. From their inception, Cajas are required to channel the surpluses that are not allocated to reserves toward
project that fall under their "Obra Social" scheme (community investments projects).
Spanish Cajas are subjects to the same legislation that applies to other types of credit institutions (commercial and cooperative banks) in terms of
transparency, solvency and consolidation.
Confederación Española de Cajas de Ahorros - C/ Alcalá 27  28014 Madrid  Tel: +34 91 596 50 00
 www.ceca.es
ANSWER ON IASB ED/2010/5
PRESENTATION OF ITEMS OF OTHER COMPREHENSIVE INCOME
refer to paragrahs
Statement of profit or loss and other comprehensive income
Question 1
The Board proposes to change the title of the statement of 10,BC21
comprehensive income to ‘Statement of profit or loss and other
comprehensive income’ when referred to in IFRSs and its other
publications. Do you agree? Why or why not? What alternative do you
propose?
Response to Question 1
CECA agrees with the proposal.
Question 2
The proposals would require entities to present a statement of profit or 12, 81,
loss and other comprehensive income with two sections— profit or loss BC17and items of other comprehensive income. The Board believes this will BC19
provide more consistency in presentation and make financial statements
more comparable. Do you agree? Why or why not? What alternative do
you propose?
Response to Questions 2 and 5
CECA is concerned about the extended use of other comprehensive
income. Particularly in case of items traditionally accounted in net
income, the Boards should make a great effort in training users,
preparers and stakeholders as well as in the definition of an appropriate
presentation in order to achieve a correct analysis of financial
statements prepared under the proposal.
2
Presentation of items of other comprehensive income
Question 3
The exposure draft proposes to require entities to present items of other
comprehensive income (OCI) that will be reclassified to profit or loss
(recycled) in subsequent periods upon derecognition separately from
items of OCI that will not be reclassified to profit or loss. Do you
support this approach? Why or why not? What alternative do you
propose, and why?
82A,
BC25
y
BC26
Response to Question 3
CECA agrees with the proposed approach.
Question 4
The exposure draft also proposes to require that income tax on items 91,
presented in OCI should be allocated between items that might be BC27subsequently reclassified to profit or loss and those that will not be BC29
reclassified subsequently to profit or loss, if the items in OCI are
presented before tax. Do you support this proposal? Why or why not?
What alternative do you propose and why?
Response to Question 4
CECA agrees with the proposed approach.
Benefits and Costs
Question 5
In the Board’s assessment:
BC32BC36
(a) the main benefits of the proposals are:
(i) presenting all non-owner changes in equity in the same
statement.
(ii) improving comparability by eliminating options currently in IAS
3
1.
(iii) maintaining a clear distinction between profit or loss and items
of other comprehensive income.
(iv) improving clarity of items presented in OCI by requiring them
to be classified into items that might be reclassified subsequently to
profit or loss and items that will not be reclassified subsequently to
profit or loss.
(b) the costs of the proposals should be minimal because in applying
the existing version of IAS 1, entities must have all the information
required to apply the proposed amendments. Do you agree with the
Board’s assessment? Why or why not?
Response to Question 5
This question has been already answered in question 2.
Other comments
Question 6
Do you have any other comments on the proposals?
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